The Global Minimum Tax | Selected Issues on Pillar Two

1. Introduction

After a decade-long endeavour led by various international intergovernmental and non-governmental organizations, consensus has been achieved for imposition of a global minimum tax through the OECD Pillar Two framework. While this measure has been embraced, certain fundamental technical aspects continue to be contentious. These issues range from the determination of revenue thresholds to the use of accounting standards and the concept of jurisdictional blending. Despite S. 528these issues being the subject of extensive deliberation during the initial public consultations due to their direct impact on revenue generation, their importance has been overshadowed by discussions concerning the under taxed profits rule (UTPR) and qualified domestic minimum top-up tax (QDMTT). Nevertheless, it must be acknowledged that the final version of the GloBE Model Rules incorporates inputs from the consultations. However, the question arises as to whether these technical aspects, given their direct impact on revenue generation effectiveness, warrant further discussion to ensure that the final version effectively achieves the objective of implementing a global minimum tax.

The efficacy of imp...